OMB Briefing

April 6, 2011
What are we proposing for 

major sources?

 We are proposing MACT standards for new and 

existing PVC production facilities at major sources 

 In 2004 the major source MACT was vacated

 Court said EPA failed to show that regulating VC 

satisfied requirements to regulate all HAP

 Now under settlement agreement with LEAN, MEAN 

and Sierra Club requiring Administrator’s signature on 

the proposal by April 15, 2011
What are we proposing for area 

sources?

 On January 23, 2007, EPA promulgated standards for 

area sources

 Established GACT standards for VC equivalent to part 61 

VC NESHAP, which covers process vents, stripped resins, 

wastewater and equipment leaks

 We are proposing to review and revise those standards

 Vinyl chloride standards under CAA 112(d)(6)

 Total HAP standards under CAA 112(d)(5) 

 Dioxin and HCl standards under CAA 112(d)(2) 

 Include standards for heat exchange systems and storage 

vessels 
Why are we addressing area source 

standards in this rulemaking proposal?

 Area sources should be regulated commensurate with 

major sources given unique circumstances surrounding this 

category

 The area source is located in the community that sued us

 Litigants filed a Petition against the United States for 

violating their right to equal environmental protection, 

citing effects from industrial facilities in Mossville, LA and 

EPA’s failure to set MACT standards

 CNN's Toxic's Town Series featured Mossville residents and 

their exposure to chemicals from chemical plants including 

the CertainTeed Corporation area source
Why are we proposing area source 

standards equivalent to MACT levels for 

major sources?

 At the time of the 2007 area source promulgation, we were 

unaware that there were any area sources

 Only area source is CertainTeed Corporation in Mossville, LA

 It is a “synthetic” area source and would emit at major source 

levels except for thermal oxidizer required by Louisiana 

 114 survey information we collected shows no substantial 

differences between this source and other major sources, with 

the exception of their stripped resin

 Area and major sources have similar emissions

 Area and major sources use the same types of control devices
What are we proposing to do?

 Set standards for all PVC area and major sources:

 Process vents (recovery system and activate carbon injection/fabric filter)

 PVC stripped resin (steam stripping)

 Equipment leaks (LDAR)

 Wastewater (steam stripping)

 Heat exchange systems (equipment leak program)

 Storage vessels 

 Set emission limits for:

 Vinyl chloride

 Total HAP

 Dioxin & furans (as TEQ)

 Hydrogen chloride (HCl)

 Set monitoring requirements:

 Annual source testing

 Parametric monitoring
Summary of Industry Emission Reductions by Facility 

(tons per year)

Emission Reduction (Tons per Year)

Company/Facility VC HCl CDD/CDF Total HAP

Certain Teed - Lake Charles 2.61E-01 6.74E-01 5.56E-11 53.5

Dow - Midland 4.71 0 0 64.9

Formosa - Delaware 3.64 1.40 0 32.5

Formosa - Baton Rouge 2.69E-01 0.649 6.12E-10 51.6

Formosa - Point Comfort 2.20 0 2.05E-08 65.2

Georgia Gulf - Plaquemine 69.0 29.7 3.05E-09 544

Georgia Gulf - Aberdeen 12.4 1.03 0 160

OxyVinyls - Deer Park 3.20E-01 0 0 53.3

OxyVinyls - Pedricktown 1.47 0 0 53.7

OxyVinyls - Pasadena 7.72 3.50 0 60.6

Poly One - Henry 5.46E-01 0 0 55.6

Poly One - Pedricktown 2.75E-03 3.38E-06 0 51.6

Shintech - Addis 1.85E-01 0 0 51.6

Shintech - Freeport 2.46E-01 0 0 2.72E-01

Shintech - Plaquemine 27.0 5.24 0 281

Westlake - Calvert City 23.1 0 0 197

Westlake - Geismar 8.64 0 2.15E-09 61.2

TOTAL 162 42.2 2.64E-08 1,838
Summary of Control Equipment and Testing and 

Monitoring Costs by Facility

Company/Facility

Costs

Control Equipment Costs Testing, Monitoring, and 

Recordkeeping Total MACT Floor Costs

TCI

($)

TAC

($/yr)

TCI

($)

TAC

($/yr)

TCI

($)

TAC

($/yr)

Certain Teed - Lake 

Charles 2,478,892 640,921 822,094 166,349 3,300,986 807,270

Dow – Midland 0 734,831 822,094 146,106 822,094 880,937

Formosa - Baton Rouge 1,370,686 2,465,545 822,094 162,383 2,192,780 2,627,928

Formosa - Delaware City 228,339 392,667 822,094 157,613 1,050,433 550,280

Formosa - Point Comfort 1,092,721 685,224 822,094 174,164 1,914,815 859,388

Georgia Gulf - Aberdeen 281,037 843,327 822,094 199,606 1,103,131 1,042,933

Georgia Gulf -

Plaquemine 2,482,459 4,039,552 822,094 157,613 3,304,553 4,197,165

OxyVinyls - Deer Park 0 116,906 822,094 179,531 822,094 296,437

OxyVinyls - Pasadena 2,819,692 1,727,353 822,094 195,802 3,641,786 1,923,155

OxyVinyls - Pedricktown 0 711,570 822,094 80,189 822,094 791,758

PolyOne - Henry 0 309,244 822,094 169,804 822,094 479,048

PolyOne - Pedricktown 0 248,690 822,094 148,077 822,094 396,767

Shintech – Addis 2,901,430 2,784,381 822,094 157,054 3,723,524 2,941,435

Shintech - Freeport 0 828,746 822,094 145,713 822,094 974,459

Shintech - Plaquemine 7,458,644 5,547,552 822,094 169,356 8,280,738 5,716,907

Westlake - Calvert City 1,339,481 1,340,999 822,094 160,259 2,161,575 1,501,258

Westlake - Geismar 5,787,431 3,219,230 822,094 156,132 6,609,525 3,375,362

TOTAL 28,240,812 26,636,737 13,975,598 2,725,751 42,216,410 29,362,487